

sMfy 


BUREAU  OE 
RAILWAY  ECONOMICS 


LOGAN  C.  MCPHERSON 

DIRECTOR 


FRANK  HAIGH  DIXON 

CHIEF  STATISTICIAN 


The  Conflict  Between 


Federal  and  State  Regulation 
of  the  Railways 


BULLETINS  OF  THE 

BUREAU  OF  RAILWAY  ECONOMICS 

- , . 


1 . Summary  of  Revenues  and  Expenses  of  Steam  Roads  in  the 

United  States  for  July,  1910.  (Monthly  Report  Series, 
Bulletin  No.  1.) 

2.  Summary  of  Revenues  and  Expenses  of  Steam  Roads  in  the 

United  States  for  August,  1910.  (Monthly  Report  Series, 
Bulletin  No.  2.) 

3.  Summary  of  Revenues  and  Expenses  of  Steam  Roads  in  the 

United  States  for  September,  1910.  (Monthly  Report 
Series,  Bulletin  No.  3.) 

4.  A Comparative  Statement  of  Physical  Valuation  and  Capitali- 

zation. 


3.  Preliminary  Bulletin  for  November,  1910 — Revenues  and 
Expenses. 

6.  Railway  Traffic  Statistics. 

7.  Summary  of  Revenues  and  Expenses  of  Steam  Roads  in  the 

United  States  for  October,  1910.  (Monthly  Report  Series, 
Bulletin  No.  4.) 

8.  Summary  of  Revenues  and  Expenses  of  Steam  Roads  in  the 

United  States  for  November,  1910.  (Monthly  Report 
Series,  Bulletin  No.  5.) 

9.  Summary  of  Revenues  and  Expenses  of  Steam  Roads  in  the 

United  States  for  December,  1910.  (Monthly  Report 
Series,  Bulletin  No.  6.) 

10.  Summary  of  Revenues  and  Expenses  of  Steam  Roads  in  the 

United  States  for  January,  1911. 

11.  Comment  on  the  Decision  in  the  Western  Advanced  Rate  Case, 

No.  3500.  (Out  of  Print.) 

12.  Summary  of  Revenues  and  Expenses  of  Steam  Roads  in  the 

United  States  for  February,  1911. 

13.  Summary  of  Revenues  and  Expenses  of  Steam  Roads  in  the 

United  States  for  March,  1911. 


(i Continued  on  third  page  of  cover.) 


The  numbering  of  the  monthly  bulletins  as  a separate  series  was  abandoned 
with  the  December  issue.  Since  then  all  bulletins  issued  by  the  Bureau  have 
been  given  a consecutive  number  only. 


The  Conflict  Between 
Federal  and  State  Regulation 
of  the  Railways 


DUKE  UNIVERSITY  LIBRARY 
DURHAM,  N.  C. 


Form  934— 20M— 8-34— C.P.Co. 


WASHINGTON,  D.  C. 
JUNE,  1911 


PREFACE. 


£>^2.  ft 

V'-o.  \5 


/ / - / rw?; 

A recent  letter  from  Mr.  Edwin  A.  Pratt,  the  English  writer 
on  railways,  to  the  Director  of  the  Bureau  of  Railway  Eco- 
nomics, says: 

“I  should  very  much  like  to  have  for  the  purposes 
of  a work  on  which  I am  now  engaged,  a few  facts  as  to 
the  nature  and  extent  of  the  control  exercised  by  the 
various  States — supplementing  that  of  the  Interstate 
Commerce  Commission — on  the  railways  of  your  coun- 
try. At  a meeting  last  night  of  the  Political  Economy 
Club,  to  which  I was  invited  as  a guest,  a discussion  was 
started  on  the  subject  during  which  the  view  was  ex- 
pressed that  the  control  by  the  States  was  becoming  so 
oppressive  that  it  would  be  difficult  for  the  country  to 
avoid  being  forced  into  government  ownership  of  the 
railways  in  the  proximate  future,  and  there  was  a very 
interesting  debate  thereon. 

“Would  it  be  troubling  you  too  much  to  favor  me 
with  a few  details  which  would  enable  me  to  state  the 
position  clearly?” 

In  the  thought  that  the  statement  prepared  in  response 
to  Mr.  Pratt’s  request  may  be  of  interest  to  the  members 
of  the  Bureau,  it  is  incorporated  in  this  bulletin. 


P615Q7 


Digitized  by  the  Internet  Archive 
in  2016 


https://archive.org/details/conflictbetweenf01asso 


THE  CONFLICT  BETWEEN  FEDERAL  AND  STATE 
REGULATION  OF  RAILWAYS. 


For  convenience  of  reference  the  provisions  of  the  Consti- 
tution of  the  United  States  conferring  and  limiting  the  powers 
of  Federal  and  State  regulation  of  railways  are  set  forth  as 
follows : 

The  Congress  shall  have  power:  * * * To  regu- 

late commerce  with  foreign  nations  and  among  the 
several  States,  * * *.  Section  8,  Article  I. 

This  Constitution,  and  the  laws  of  the  United  States 
which  shall  be  made  in  pursuance  thereof,  * * * 

shall  be  the  supreme  law  of  the  land,  and  the  judges 
in  every  State  shall  be  bound  thereby,  anything  in  the 
Constitution  or  laws  of  any  State  to  the  contrary  not- 
withstanding. Paragraph  2,  Article  VI. 

The  powers  not  delegated  to  the  United  States,  by 
the  Constitution,  nor  prohibited  by  it  to  the  States,  are 
reserved  to  the  States  respectively,  or  to  the  people. 
Amendment  X. 

No  person  shall  * * * be  deprived  of  life,  lib- 

erty or  property,  without  due  process  of  law ; nor  shall 
private  property  be  taken  for  public  use  without  just 
compensation.  Amendment  V. 

* * * nor  shall  any  State  deprive  any  person  of 

life,  liberty  or  property,  without  due  process  of  law, 
nor  deny  to  any  person  within  its  jurisdiction  the  equal 
protection  of  the  laws.  Section  1,  Amendment  XIV. 

The  effect  of  these  provisions  of  the  Constitution  upon  the 
power  of  the  Federal  Government  and  the  States  to  regulate 
railways  may  be  summarized  as  follows : 

The  Federal  Government  exercises  delegated  powers  only; 
all  powers  not  expressly  delegated  to  it  by  the  Constitution 


P815G7 


6 


or  prohibited  to  the  States  may  he  exercised  by  the  States. 
In  the  exercise  of  its  delegated  powers  the  Federal  Govern- 
ment is  supreme,  but  the  power  of  a State  over  any  matter 
as  to  which  power  has  been  delegated  to  Congress,  is  largely 
determined  by  the  question  of  whether  Congress  has  exercised 
its  delegated  power  as  affecting  this  subject-matter.  If  a 
Federal  law  is  construed  as  regulating  the  whole  of  any 
subject-matter  as  to  which  power  has  been  delegated  to  Con- 
gress or  if  State  regulation  conflicts  with  any  Federal  law, 
such  State  legislation  is  void.  As  the  Federal  Government 
is  constantly  exercising  to  a fuller  extent  the  power  to  regulate 
interstate  commerce,  the  necessary  tendency  is  to  restrict  the 
powers  of  the  States. 

Under  Section  8,  Article  I of  the  Constitution,  exclusive 
power  to  regulate  railway  operations,  practices  and  charges 
affecting  the  transportation  of  persons  or  property  where,  in 
the  course  of  such  transportation,  State  lines  are  crossed,  is 
delegated  to  the  Federal  Government,  the  only  restriction 
upon  its  power  in  this  field  being  the  provision  of  Amendment 
V that  “No  person  shall  be  * * * deprived  of  life,  lib- 

erty, or  property,  without  due  process  of  law;  nor  shall  pri- 
vate property  he  taken  for  public  use  without  just  compen- 
sation.” It  follows  that  it  is  not  within  the  power  of  Congress 
to  impose  regulations  which  shall  have  the  effect  of  depriving 
the  railway  company  of  its  property  without  due  process  of 
law  or  of  taking  its  property  without  just  compensation,  and 
the  United  States  Supreme  Court  has  held  that  the  use  of 
property,  in  all  legitimate  ways,  is  as  much  a right  of  prop- 
erty protected  by  the  Constitution  as  is  the  property  itself. 

The  power  to  regulate,  commerce  wholly  within  a State,  not 
having  been  delegated  to  Congress,  is  reserved  to  the  States, 
respectively,  under  Amendment  X of  the  Constitution.  This 
gives  to  each  State  plenary  power  over  all  commerce  or  trans- 
portation which  begins  and  ends  within  its  borders,  subject, 
however,  to  the  provision  of  Section  1,  Amendment  XIV,  which 
provides  that  no  State  shall  “deprive  any  person  of  life, 
liberty  or  property  without  due  process  of  law;  nor  deny  to 


7 


any  person  within  its  jurisdiction  the  equal  protection  of  the 
laws.  ” 

As,  with  few  and  unimportant  exceptions,  the  railways  of 
the  United  States  are  engaged  in  interstate  commerce  as  well 
as  in  intrastate  commerce,  it  is  inevitable,  under  our  dual  sys- 
tem of  government,  that  questions  should  arise  as  to  the  exact 
location  of  the  line  separating  the  jurisdiction  of  the  Federal 
Government  from  that  of  the  several  States.  This  is  fre- 
quently illustrated  by  questions  as  to  whether  the  effect  of 
regulations  imposed  by  State  authority  may  be  to  regulate 
or  burden  interstate  commerce.  It  is  the  duty  of  all  of  the 
courts,  State  and  Federal,  to  determine  questions  that  arise 
as  to  whether  an  act  of  Congress  is  made  in  pursuance  of  the 
Constitution  of  the  United  States;  and  as  to  whether  any 
provision  of  a State  Constitution,  or  any  act  of  a State  Legis- 
lature is  in  violation  of  any  provision  of  the  Constitution  of 
the  United  States.  The  United  States  Supreme  Court  is  the 
final  tribunal  on  all  questions  of  Constitutional  construction. 

As  questions  as  to  the  extent  of  the  regulative  powers,  both 
of  the  Federal  Government  and  of  the  States,  are  constantly 
being  presented  to  the  United  States  Supreme  Court,  the 
decisions  of  this  court  are  gradually  defining  more  sharply 
the  extent  of  the  Federal  and  State  powers,  respectively,  and 
drawing  the  dividing  line  between  them  more  clearly.  The 
tendency  of  the  decisions  of  this  court  seem  to  be  strongly 
in  the  direction  of  the  proposition  that  interstate  railways 
must,  in  all  substantial  respects,  be  subject  to  one  power,  and 
the  court  now  manifests  a more  decided  tendency  than  in 
former  years  to  hold  that  regulations  of  intrastate  commerce 
which  have  the  effect  of  regulating  or  burdening  interstate 
commerce,  are  void  as  trenching  upon  the  power  delegated  to 
Congress  to  regulate  commerce  among  the  States.  There  are 
some  apparent  exceptions  to  this,  as  in  cases  in  which  it  has 
been  held  that,  under  its  police  power,  a State  may  prescribe 
regulations  affecting  the  movement  of  interstate  commerce 
so  long  as  such  regulations  only  indirectly  affect  interstate 
commerce  and  do  not  regulate  or  burden  it.  An  illustration 


8 


of  this  is  the  enactment  by  a State  prescribing  tests  for  color- 
blindness for  locomotive  engineers  engaged  within  that  State 
in  the  operation  of  interstate  trains. 

While  each  State  possesses  exactly  the  same  power  as  to 
matters  within  its  jurisdiction  as  is  possessed  by  each  of  the 
other  States,  this  power  has  been  used  in  as  many  different 
ways  as  there  are  States  in  the  Union,  with  the  result  that 
every  interstate  railway,  in  addition  to  being  subject  to  the 
regulations  imposed  by  the  Federal  Government,  is  subject 
to  a different  set  of  regulations  in  each  State  which  it 
traverses. 

Some  of  the  States  have  used  only  a small  fraction  of  their 
power  to  regulate  intrastate  commerce;  others  have  endeav- 
ored to  go  far  beyond  it  and  have  been  kept  within  bounds 
only  by  the  courts. 

State  regulative  power  has  been  exercised  in  a variety  of 
ways.  In  some  cases  specific  regulations  have  been  enacted 
by  State  laws,  and  in  other  cases  they  have  been  prescribed 
by  commissions  under  power  delegated  by  the  State  Legis- 
latures. Regulations  have  been  prescribed  covering  passenger 
and  freight  charges,  train  operation,  car  supply,  character 
of  equipment  and  station  buildings,  hours  of  labor  of  em- 
ployees and  conditions  of  employment,  safety  appliances,  and 
almost  every  conceivable  phase  of  railway  operation. 

State  acts  and  regulations  prescribing  maximum  charges  for 
the  transportation  of  passengers  and  freight  have  caused  much 
of  the  litigation  between  the  railways  and  the  States,  and  have 
frequently  been  held  to  be  unconstitutional  on  the  ground  that 
the  charges  prescribed  were  so  low  as  to  be  confiscatory  under 
the  Fourteenth  Amendment,  that  they  would  deprive  the  rail- 
way of  a reasonable  return  upon  the  value  of  its  property.  It  is 
the  contention  of  some  aide  lawyers  that  the  courts  must  ulti- 
mately go  farther  and  hold  that  under  the  Constitution  of 
the  United  States,  just  as  under  the  Common  Law  of  England, 
the  railway  cannot  be  deprived  by  legislation  of  just  and  rea- 
sonable compensation  for  each  specific  transportation  service; 
that  small  profits  will  not  justify  the  making  of  a greater 


9 


charge,  and  that  large  profits  will  not  justify  a lesser  charge 
being  fixed  by  any  governmental  authority.  It  is  contended 
that  the  right  given  to  the  railways  by  the  present  interstate 
commerce  law  to  make  a reasonable  charge  for  each  service 
is  but  the  legislative  expression  of  a Constitutional  right. 

In  some  of  the  States  efforts  have  been  made  to  prevent  the 
railways  from  testing  the  validity  of  State  regulations  in  the 
courts. 

Minnesota,  in  a freight  rate  act,  and  North  Carolina,  in 
passenger  and  freight  rate  acts  attempted  to  do  this  by  pre- 
scribing such  severe  penalties  for  the  violation  of  the  acts  as 
to  force  the  companies  to  comply  therewith  rather  than  run 
the  risk  of  failing  to  prove  the  invalidity  of  the  acts  in  criminal 
prosecutions.  The  Supreme  Court  of  the  United  States  held 
all  of  these  acts  to  be  unconstitutional  and  void. 

Alabama,  Arkansas,  and  Missouri  attempted  to  keep  the 
railways  out  of  the  United  States  courts  by  statutes  which 
provided  that  any  corporation  chartered  in  any  other  State 
which  should  resort  to  a United  States  court  should  forfeit 
its  right  to  do  intrastate  business  in  that  State.  These  laws 
were  overthrown  by  the  United  States  Supreme  Court  as 
denying  to  the  foreign  corporations  equal  protection  of  the 
laws. 

Section  720  of  the  Revised  Statutes  of  the  United  States, 
provides  that  “the  writ  of  injunction  shall  not  be  granted  by 
any  court  of  the  United  States  to  stay  proceedings  in  any 
court  of  a State  * * With  this  provision  in  view, 

Virginia  attempted  to  evade  the  jurisdiction  of  the  United 
States  courts  by  creating  a Corporation  Commission  with  the 
powers  of  a court  and  fixing  railway  charges  by  court  decrees 
rather  than  by  acts  of  a legislative  nature.  This  failed  to  be 
sustained  by  the  United  States  Supreme  Court,  as  it  was 
held  that,  in  fixing  railway  charges,  the  Virginia  Corporation 
Commission,  notwithstanding  its  powers  and  its  form  of  pro- 
cedure, was  exercising  legislative  power  and  not  judicial 
power. 

As  would  naturally  be  supposed,  the  States  have  been  com- 


10 


peting  with  each  other  for  the  purpose  of  securing  advantages 
of  commerce  within  their  respective  borders  over  that  of  any 
other  State  and  over  interstate  commerce.  This  rivalry  has 
been  strikingly  manifested  in  laws  and  regulations  affecting 
car  service.  These  have  generally  been  termed  “reciprocal 
demurrage”  laws  and  have  been  based  on  the  false  theory  that 
a demurrage  charge  imposed  by  a railway  bears  a reciprocal 
relation  to  a legislative  penalty  for  failure  to  provide  a car 
when  demanded  by  a shipper. 

The  natural  effect  of  such  laws  in  times  of  car  shortage 
would  be  to  compel  an  interstate  road  to  discriminate  in  favor 
of  intrastate  commerce  in  the  State  imposing  the  highest  pen- 
alties, as  against  intrastate  commerce  in  other  States  and 
against  interstate  commerce.  North  Carolina  has  gone  far- 
ther than  any  other  State  in  legislation  of  this  character, 
having  enacted  a law  providing  that,  upon  failure  to  provide 
a car  within  48  hours  after  demand,  the  railway  should  pay 
$25.00  for  the  first  day  and  $5.00  for  each  subsequent  day,  the 
penalty  for  failure  to  provide  facilities  for  less  than  carload 
shipments  being  $12.50  for  the  first  day  and  $2.50  for  each 
subsequent  day.  Subsequent  legislation  reduced  these  penal- 
ties. It  may  be  that  if  a State  should  go  to  such  extremes  in 
this  direction  as  to  create  material  discriminations  against, 
or  impose  material  burdens  upon,  interstate  commerce,  such 
penalty  laws  would  be  held  to  be  unconstitutional  and  void. 

It  will  be  seen  that  the  effect  of  the  recent  decisions  of  the 
United  States  Supreme  Court  and  of  the  fuller  exercise  of  the 
legislative  powers  of  Congress  have  been  to  give  a broad  con- 
struction to  the  clause  of  the  Constitution  delegating  to  the 
Congress  power  to  regulate  interstate  commerce  and  to  con- 
fine the  power  of  the  States  within  much  narrower  limits  than 
those  over  which  many  of  them  have  sought  to  exercise  it. 
A recent  decision  by  United  States  Circuit  Judge  Sanborn 
of  the  United  States  Circuit  Court  for  the  District  of  Minne- 
sota, goes  so  far  in  this  direction  that  if  it  shall  be  sustained 
by  the  United  States  Supreme  Court  and  carried  to  its  logical 
conclusion,  it  would  seem  to  restrict  the  opportimities  of 


11 


the  States  for  oppressive  regulation.  The  Legislature  of  the 
State  of  Minnesota  had  enacted  statutes  reducing  passenger 
fares  within  that  State  about  331XJ  per  cent  and  reducing 
freight  charges  on  certain  commodities  within  the  State  about 
7.37  per  cent.  By  orders  of  the  Minnesota  Railroad  and  Ware- 
house Commission,  general  merchandise  freight  charges  on 
shipments  wholly  within  the  State  were  reduced  by  from  20 
to  25  per  cent  and  certain  specific  charges  on  freight  shipped 
from  distributing  points  just  within  the  borders  of  the  State 
to  other  points  in  the  State  were  reduced.  Suits  were  brought 
by  shareholders  of  the  railways  affected  by  these  legislative 
acts  and  orders  of  the  Commission,  against  the  railway  com- 
panies, the  Attorney  General  of  the  State,  and  the  Members 
of  the  Railroad  and  Warehouse  Commission  to  prevent  them 
from  maintaining  the  reduced  fares  and  rates  on  the  grounds 

(1)  that  the  orders  of  the  Commission  and  the  acts  of  the 
Legislature  described,  substantially  burdened  and  regulated 
Interstate  commerce  on  the  railroads  of  these  companies,  and 

(2)  that  their  necessary  effect  was  the  confiscation  of  the  prop- 
erty of  the  companies.  Judge  Sanborn  found  that  “each  of 
those  acts  and  orders  is  violative  of  the  Fourteenth  Amend- 
ment of  the  Constitution  and  void.”  He  further  found  that 
“each  of  the  acts  and  orders  challenged  has  the  natural  and 
necessary  effect  substantially  to  burden  and  directly  to  regu- 
late interstate  commerce,  to  create  undue  and  unjust  discrim- 
inations between  localities  in  Minnesota  and  those  in  adjoin- 
ing States,  and  it  is  unconstitutional  and  void.”  Interest  in 
this  decision  centers  in  the  finding  last  quoted  above. 

In  this  case  the  companies  for  the  first  time  made  an  effec- 
tive showing  upon  the  facts  as  to  the  effect  of  State  regula- 
tions upon  interstate  commerce  and  demonstrated  that,  al- 
though the  regulations  on  their  face  related  only  to  intrastate 
commerce,  the  effect  of  their  application  would  necessarily 
be  to  require  reductions  of  interstate  charges.  Upon  this 
showing  Judge  Sanborn’s  decision  was  founded  on  the  follow- 
ing propositions: 

“To  the  extent  necessary  completely  and  effectually  to  pro- 


12 


tect  the  freedom  of  and  to  regulate  interstate  commerce  the 
nation  by  its  Congress  and  its  courts  may  affect  and  regulate 
intrastate  commerce,  but  no  farther. 

“To  the  extent  that  it  does  not  substantially  burden  or 
regulate  interstate  commerce  a State  may  regulate  the  intra- 
state commerce  within  its  borders,  but  no  farther. 

“If  the  plenary  power  of  the  nation  to  protect  the  freedom 
of  and  to  regelate  interstate  commerce  and  the  attempted 
exercise  by  a State  of  its  power  to  regulate  intrastate  com- 
merce, or  the  attempted  exercise  of  any  of  its  other  powers, 
impinge  or  conflict,  the  former  must  prevail  and  the  latter 
must  give  way,  because  the  Constitution  and  the  acts  of 
Congress  passed  in  pursuance  thereof  are  the  supreme  law  of 
the  land,  and  ‘that  which  is  not  supreme  must  yield  to  that 
which  is  supreme.’  ” 

Charges  for  interstate  transportation  and  for  intrastate 
transportation  on  the  railways  of  the  United  States  are  so 
intimately  interwoven  and  are  so  closely  interdependent  that, 
should  Judge  Sanborn’s  decision  be  sustained  by  the  United 
States  Supreme  Court,  it  will  substantially  deprive  the  States 
of  the  power  of  fixing  transportation  charges.  It  would  seem 
also  that,  if  carried  to  its  logical  conclusion,  it  may  prevent 
the  States  from  enacting  so-called  “reciprocal  demurrage” 
laws  carrying  penalties  for  failure  to  supply  cars  so  severe 
as  practically  to  compel  the  railways,  in  times  of  car  shortage, 
to  discriminate  in  favor  of  intrastate  traffic. 

On  the  whole,  the  danger  of  control  by  the  States  “becoming 
so  oppressive  that  it  will  be  difficult  for  the  country  to  avoid 
being  forced  into  government  ownership  in  the  proximate 
future”  is  undoubtedly  much  less  than  it  seemed  to  be  a few 
years  ago  when  the  wave  of  drastic  regulation  was  sweeping 
over  the  State  Legislatures  and  commissions  and  their  acts 
and  orders  had  not  yet  been  passed  upon  by  the  courts. 

Of  course,  as  a practical  matter,  the  powers  reserved  to 
the  States  include  some  which  do  not  in  any  way  conflict  with 
the  delegation  to  Congress  of  the  power  to  regulate  commerce 


13 


among  the  States  and  which  may  still  be  used  to  an  unreason- 
able degree,  or  so  as  to  become  oppressive. 

By  way  of  illustration,  it  may  be  mentioned  that  the  com- 
missions in  some  of  the  States  show  a tendency  to  require 
unreasonable  and  extravagant  expenditures  by  the  railways 
in  the  provision  of  large  and  handsome  passenger  stations  at 
relatively  small  towns  and  to  make  unreasonable  requirements 
as  to  the  maintenance  of  roadbed  and  equipment,  as  to  the 
minimum  number  of  employees  to  be  assigned  to  the  opera- 
tion of  trains,  as  to  the  stopping  of  express  trains  at  unimpor- 
tant stations.  These  powers  might  be  exercised  to  an 
unreasonable  and  oppressive  extent  and  it  still  be  difficult  to 
show  that  the  results  were  confiscatory. 

It  is  possible,  also,  that  the  power  of  taxation  may  be  so 
exercised  by  the  States  as  to  become  in  some  degree  oppres- 
sive. However,  the  exercise  of  this  power  must  fall  short 
of  what  the  United  States  courts  would  find  to  be  confiscatory, 
and  it  can  not  be  so  exercised  as  radically  to  discriminate 
against  railway  property  without  coming  in  conflict  with  the 
provision  of  the  Constitution  of  the  United  States  guarantee- 
ing the  equal  protection  of  the  laws.  The  tendency  in  the 
direction  of  increasing  taxation  may  be  illustrated  by  citing 
the  fact  that  for  the  fiscal  year  ended  June  30,  1900,  the  rail- 
ways of  the  United  States  paid  taxes  levied  under  State, 
county,  and  municipal  authority  amounting  to  $48,332,273, 
while  in  1910  such  taxes  amounted  to  $104,144,076.  Part  of 
this  increase  is  to  be  accounted  for  by  the  increased  mileage 
in  1910  as  compared  with  1900,  but  the  average  payments 
of  taxes  per  mile  in  1900  amounted  to  only  $254.78  as  com- 
pared with  $435.65  in  1910,  an  increase  in  the  ten  years  of 
$180.87  per  mile  or  70.9  per  cent. 


Date  Due 

Form  335 — 35M— 9-34— C.  P.  Co. 

BULLETINS  OF  THE 
BUREAU  OF  RAILWAY  ECONOMICS 


{Continued.) 

1 4.  Summary  of  Revenues  and  Expenses  of  Steam  Roads  in  the 

United  States  for  April,  1911. 

15.  The  Conflict  Between  Federal  and  State  Regulation  of  the 

Railways. 

16.  Summary  of  Revenues  and  Expenses  of  Steam  Roads  in  the 

United  States  for  May,  1911. 

17.  Railway  Wage  Increases  for  the  year  ending  June  30,  1911. 
Retrenchment  in  the  Railway  Labor  Force  in  1911. 

18.  Capitalization  and  Dividends  of  the  Railways  of  Texas,  Year 

Ending  June  30,  1909. 

385  555’ 8B  no  ,15  P6150?  I 

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385  B952B 


no . 15 


P61507 


